enterprise avenue site, pa · 2020. 11. 4. · ar30003. record of decision remedial alternative...

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United States Environmental Prowction Agency Office of Emergency «nd Remediel Response EPA/RODJR03-84/OG3 May 1984 , \ Superfund Record of Decision: Enterprise Avenue Site, PA FOR REFERENCE ONLY Do Not Take From This Room ERA Report Cpllection y i Information; Resource Center '#'>••• HI* . BlifcJii'tiBjV^-.^X^"^ _______ US EPA 7j^FjF 8 .«saa.i.i

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  • United StatesEnvironmental ProwctionAgency

    Office ofEmergency «ndRemediel Response

    EPA/RODJR03-84/OG3May 1984 , \

    SuperfundRecord of Decision:

    Enterprise Avenue Site, PA

    FOR REFERENCE ONLYDo Not Take From This Room

    ERA Report Cpllection yi Information; Resource • Center

    '#'>••• HI* . BlifcJii'tiBjV^-.̂ X^"^_______ US EPA7ĵ FjF8.«saa.i.i

  • TECHNICAL REPORT DATA(Please read Instructions on the reverse before completing}1. REPORT NO.

    EPA/ROD/RO3-84/0032. 3. RECIPIENT'S ACCESSION NO.

    4. TITLE AND SUBTITLESUPERFUND RECORD OF DECISIONEnterprise Avenue Site, PA

    S. REPORT DATE05/10/84

    «. PERFORMING ORGANIZATION CODE

    7. AUTHOH(S) 8. PERFORMING ORGANIZATION REPORT NO.

    9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.

    11. CONTRACT/GRANT NO.

    12. SPONSORING AGENCY NAME AND ADDRESSU. S. Environmental Protection Agency401 "M" Street, S. W.Washington, D. C. 20460

    13. TYPE OF REPORT AND PERIOD COVEREDFinal ROD Report

    14. SPONSORING AGENCY CODE800/00

    5. SUPPLEMENTARY NOTES

    16. ABSTRACT ——————————————————————The Enterprise Avenue site is located within the City of Philadelphia. It

    encompasses approximately 57 acres and is situated within the 100-year flood plain ofthe Delaware River. It has been determined that the site is contaminated with in-dustrial and chemical wastes from the unauthorized disposal of approximately 5,000 t

  • ROD BRIEFING ISSUES

    Site; Enterprise Avenue, Pennsylvania

    Region; III

    AA, OSWERBriefing Date; May 4, 1984

    SITE DESCRIPTION

    The Enterprise Avenue site is located within the City ofPhiladelphia. It encompasses approximately 57 acres and is situatedwithin the 100-year flood plain of the Delaware River. It has beendetermined that the site is contaminated with industrial and chemicalwastes from the unauthorized disposal of approximately 5,000 to 15,000drums containing paint sludges, solvents, oils, resins, metal finishingwastes, and solid inorganic wastes.

    SELECTED ALTERNATIVE

    The off-site disposal alternative was selectee as the most cost-effective remedial action. This alternative includes: resampling andanalyzing the stockpiled soils in 100-cubic-yard lots for key indicatorparameters; on-site containment of soils which do not exceed key indi-cator limits; off-site disposal at a RCRA approved facility of soilstfhich exceed parameter limits; grading, completion of clay cap andcover, and site vegetation. The capital cost for whe selected alterna-tive is estimated to be $4,324,000 and annual O&M costs are $4,200.

    ISSVES AND RESOLUTIONS KEY WORDS

    1. The Enterprise Avenue site is a city- . Municipally-Ownedowned landfill contaminated with illegally Sitedumped industrial waste materials. The . PotentialCity has undertaken response actions at Responsiblethe site and would like to continue to Party (PRP)oversee the regaining cleanup activities.However, the City has been identified as aPotential Responsible Party (PRP). Therefore,specific criteria were developed for theCooperative Agreement to define the ratio-nale for enforcement where Fund monies willbe used by a FR? for cleanup. These cri-teria included:

    EPA's reserved right to sue

    Reiirbursement agreement betweenthe City and EPA

    -1~ AR300030

  • Enterprise Avenue, PennsylvaniaMay 4, 1984Continued

    ISSUES AND RESOLUTIONS

    The City's responsibility to con-tinue to pursue its pending law-suits against Enterprise Avenuegenerators.

    A Key Indicator Analysis (KIA) was developedand used to determine whether or not exca-vated soil was contaminated. The objectiveof the KIA was to identify those contaminantswhich were most likely to be found on-siteand of greatest concern with respect topotential environmental impacts. TechnicalReport 15 "Hot Spot Soil Handling Protocol"discusses the rationale employed in the KIAdevelopment and is included as an attachmentto the ROD.

    The recommended alternative complies withthe Part 265 RCRA closure regulations. Thisincludes ground water monitoring, a 2-footclay cover and site vegetation.

    T.-e justification for off-site disposal wasirased on the elimination of on-site disposaloptions for the following technical reasons:

    1. The high ground water table and subsur-face soils are not suitable for con-struction of a land disposal facility.

    2. There is a high possibility for dif-ferential settlement due to the presenceof organic matter in the subsurfacesoils (incinerator residue), that couldadversely affect the integrity of a landdisposal cell.

    3. Migration to the shallow ground watertable (2-5 ft.) could be expected in theevent of a release of contaminants froma disposal cell.

    KEY WORDS

    Key IndicatorAnalysisSoil Contamination

    RCRA ClosureRegulations

    Off-Site DisposOn-Site Dispose

    -2-AR30003

  • Record of DecisionRemedial Alternative Selection

    SITE; Enterprise Avenue Site, Philadelphia, Pennsylvania

    DOCUMENTS REVIEWED

    I have reviewed the following docunents describing the analysis of cost-effectiveness of remedial alternatives for the Enterprise Avenue site:

    - Enterprise Avenue Remedial Action Feasibility Study titled "RemedialAction Program, Excavation and Disposal of Hat-Spot Soil From, and Clo-sure of, the Enterprise Avenue Site, Philadelphia, Pennsylvania, datedApril 1984.

    - Summary of Remedial Alternatives Selection

    - technical reports prepared by Roy F. Weston, Inc. in September of 1981for the City of Philadelphia 15, "Hot Spot Soil Handling Protocol"and #3, "Gcoundwater and Surface Water Monitoring".

    - Responsiveness summary dated February 23, 1984.

    DESCRIPTION OF SELECTED REMEDY

    - Sampling and analysis of all soil stockpiled on-site in 100-cubic-yard lots to determine disposal requirement.

    - Off-site disposal at a RCRA approved facility of all soils which failthe Key Indicator Parameter Itest.

    - Backfilling, grading and vegetating of the site as a final cover.

    DECLARATION

    Consistent with the Comprehensive Environmental Response, Compensation,and Liability Act of 1980 (CERCLA), and the National Contingency Plan(40 CFR part 300), I have determined that the off-site disposal of con-taminated soil at the Enterprise Avenue site is a cost-effective remedyand provides adequate protection of public health, welfare, and theenvironment. The State of Pennsylvania has been consulted and agreeswith the approved remedy.

    I have also determined that the action being taken is appropriate whenbalanced against the availability of Trust Fund monies for use at othersites. In addition, the off-site transport and secure disposition inan approved facility is more cost-effective than other remedial actionsand is necessary to protect public health, welfare, and the environment.

    Lee M. ThomasAssistant Administrator

    Office of Solid Waste and Elnergency Response

    AR300032

  • SUMMARY OF REMEDIAL ALTERNATIVE SELECTIONENTERPRISE AVENUE SITE

    SITE LOCATION AND DESCRIPTION

    The Enterprise Avenue site is located within the City of Philadelphiaadjacent to the Southwest Water Pollution Control Plant and near theeastern end of Philadelphia International Airport (See Figure 1). Thecity-owned site encompasses a total of approximately 57 acres, and islocated within the 100-year flood plain of the Delaware River. Theimmediately adjacent land use is prijnarily industrial, and the closestresidential population is located slightly more than two miles northwestof the site.

    Natural marsh conditions are found at the site in isolated areas. Alow-permeability, silty clay layer underlies the site- The thicknessof this layer ranges from 5 feet to 25 feet. Multiple culverts, canals,and drainage ways introduce variability to the surface water system by.concentrating runoff. All surface drainage from the site is channeledinto Eagle Creek, which flows to Mingo Creek, then to the SchuylkillRiver, and ultimately the Delaware River.

    There are two ground water-bearing zones at the site. The first zoneis above a silty clay layer. It is under perched water table conditionsThe second ground water-bearing zone is found in the sands and gravelthat lie beneath the silty clay. The ground water in this zone is underconfined conditions. There are no known users of the ground water inthe general area; however, the deeper ground water-bearing zone may re-charge sources of ground water for portions of southern New Jersey.The observed flow in the deep aquifer is east toward the Delaware River.

    SITS

    The Biterprise Avenue site historically was part of the extensive tidalmarshland along the Delaware River. The back channel of the DelawareRiver had naturally silted-in because of extensive fanning and miningen the upper reaches of the Schuylkill and Delaware Rivers. The low-lying land in the area has been extensively filled-in for facilitiess-jch as the airport, tanker terminals, roadways, and industrial sites.Until mid- 19 76, the City of Philadelphia Streets Department used 40acres of the low-lying land to landfill primarily incinerator residueand lesser quantities of fly ash and construction/demolition debris.

    In response to reports of unauthorized dumping of industrial waste, thePhiladelphia Water Department (PWD) in late 1978 developed a work scopeto perform an initial investigation of the site conditions in consultationwith EPA. Exploratory excavations during January of 1979 uncovered approxi-mately 1,700 55-gallon drums containing industrial waste materials. The

    A R 3 0 0 0 3 3

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    DELAWARE COUNTY

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  • - 2 -

    great majority of these drums were broken and fragmented. Generally, itwas determined that the druns contained such industrial and chemicalwastes as paint sludges, solvents, oils, resins, metal finishing wastes,an3 solid inorganic wastes. The total number of drums disposed of atthe site was estimated by the FW5 to be between 5,000 and 15,000.

    The FWD undertook a response action at the site which included: A detailedsite investigation to determine the degree and extent of contamination;the development of plans and specifications to accomplish site cleanup;and procurement of a cleanup contractor to excavate and properly disposeof contaninated soil and drummed waste at an approved off-site facility.Contaminated water was also taken off-site for disposal.

    A Key Indicator Analysis (KIA) was used to determine whether or not ex-cavated soil was to be considered contaminated. The objective of the KIAwas to identify those contaminants which were most likely to be found on-site and of greatest concern with respect to potential environmentalimpacts. The list of key indicator contaminants was developed by re-viewing the records in existence which pertained to the type and quantityof waste materials buried at the site. In general, the waste materialswere organic in nature. The key indicators and their associated limitsare listed below. If any one limit were exceeded in an analysis, theentire batch of soil was considered contaminated and was taken off-sitefor disposal at an approved landfill. If none of the limits were ex-ceeded, the soil was classified as noncontaminated and remained on-siteto be used as backfill material.

    Key Indicator Analysis

    Indicator

    1. TCK (Total Organic Halogen)

    2. W3latile Organics- Benzene 12 pan- Toluene 15 pan- Ethylbenzene 15 ppn

    3. EP Tbxicity (Metals)- Arsenic 5 ppm- Barium 100 pan- Cadmium 1 pan- Chromium 5 ppn- Lead 5 ppn- Mercury 0.2 ppm- Selenium 1 pan- Silver 5 ppn

    RR300035

  • - 3 -

    In developing the limits for the key indicators, the maximum backgroundlevels present for the various parameters were identified. The upperlimits for the key organic indicators were established at 75 times themaximum background levels. As the limits were set they were compared tothe maximum fresh water criteria for reasonableness and found to be com-parable. The EP toxicity test was applied for analysis of metals only,due to the fact that the TOX indicator will detect the presence ofpesticides/herbicides. The approach taken for establishing the organiclimits (i.e., 75x) is consistent with EPA's methodology which uses 100times drinking water standards for establishing the limits for EP toxicityunder RCRA. Technical Report #5 entitled "Hot Spot Soil Handling Protocoldiscusses the rationale employed in the KIA development.

    Unfortunately, in the Fall of 1982 the K*D had to halt cleanup work at thesite due to a lack of funds available for the completion of the project,The remedial project contract cost had reached $7.2M at that time. Theinitial bid price was $4.95M. The work accomplished during 1982 included:excavation of all contaminated soil and buried drums; off-site disposalof all drummed waste material (11,600 drums uncovered); off-site disposalof approximately 226,000 gallons of contaminated water; and off-sitedisposal of 21,350 tons of the approximately 39,150 tons of contaninatedsoil present on-site. Wien the PWD realized that the funds availablewere inadequate to complete the project, they directed the contractorto stockpile the remaining 17,800 tons of excavated contaminated soilon-site (see Figure 2 for location of piles) . The City of Philadelphiaspent more than $8.35M for site cleanup and related investigative andengineering activities.

    All cleanup actions taken to date at the site by the FWD were done withthe concurrence of ERA. The Agency was intimately involved, both techni-cally and legally, in the development and implementation phases of thecleanup. All proposed actions were reviewed to assure that they compliedwith Federal environmental regulations which existed at the time.City was most cooperative in modifying it's plans in response to theAgency's comments.

    CURRENT SITE SPOTS

    two stockpiles of soil remaining on the site are the subjects of theproposed remedial action. The larger of the two piles (11,700 tons) wasdetermined to be contaminated primarily with Total Organic Halogens (TOX) .The median TCK concentration of the soil in this pile is 65 ppm, the averageis 350 ppn, and the range is 29 ppm to 5,350 ppn. The smaller pile(6,100 tons) is primarily contaminated with Volatile Crganics (i.e.Benzene, Ethylbenzene, Ttoluene) . A sunmary of the concentration valuesof the soils in the smaller pile is as follows:

    Median (ppn) Average (ppm) Range (ppn)•toluene 36 172 19 to 1,000Benzene 24 34 17 to 86Ethylbenzene 41 94 18 to 427

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  • - 4 -

    Each stockpile has been graded and covered with 9 to 12 inches of clay.The determination as to which soil would be stockpiled was based uponanalytical results produced by the cleanup contractor in the Fall of1982. (See Appendix A for results.)

    Subsequent sampling and analysis of soil fron the stockpiles performed byRoy F. Weston, Inc. in March of 1983 and March of 1984 yield results which,when compared to the original analytical results of the cleanup contractor,raise questions as to the level of contamination in the piles. The Westonresults are generally lower than the contractor's. (See Appendix B forWeston's analytical results.) This could be due to volatilization/bio-degradation of some contaminants. Also, it could be the result of non-representative sampling of the piles. In any event, re-verification ofthe degree of contamination in the soil must be done prior to final dis-position.

    Contamination at the site is limited to the confines of the two stock-piles. Ground water and surface water samples taken each month at thesite continue to indicate no measurable impact from the site on thesurrounding environment.

    A silty clay layer frcm 5 to 25 feet in thickness, which underlies the site,generally restricts movement of the surface water and shallow ground waterinto the deep water-bearing zone. As a result, most precipitation infil-trating the ground at the site drains to adjacent surface streams viadischarge of the shallow (perched) water-bearing zone rather than movingdownward into the deep water-bearing zone. However, the potential existsfor contamination frcm the stockpiled soil to leach into the deep wateraquifer, and for volatile compounds to find their way into the varioussurface streams in the area.

    ENFORCEMENT

    EPA has sent the City a letter stating that the agency does not plan toinitiate any court actions concerning Enterprise Avenue so long as theCity continues to pursue it's pending lawsuit against Enterprise Avenuegenerators, and returns half of the recovered monies to the Superfunduntil the Superfund expenses are fully repaid. EPA is not involved in

    -•any litigation or negotiations concerning generators or transporterslinked to the Enterprise site. The City's Philadelphia v. Stepan casewas filed against more than 80 generators in 1980. The City has~~alsobrought suit against transporters linked to the site.

    ALTERNATIVES EVALUATION

    The remaining cleanup action to be undertaken at the site will address thestockpiled soil. The objective of the cleanup is to provide adequate pro-tection of public health, welfare, and the environment. The alternativesfor cleanup action considered include:

    . Soil Aeration

    . Land Treatment

    . Composting

    RR300038

  • - 5 -

    . On-Site Encapsulation

    . Off-Site Disposal

    . No Action

    Since the origins of the hazardous substances discovered at the sitecould not be determined conclusively, it was assumed that the stockpiledsoil is regulated by RCRA for handling and disposal purposes. Allalternatives evaluated (except No Action) were designed to comply withRCRA technical and administrative requirements.

    The Remedial Action strategy may be an individual alternative, or a combi-nation of the alternatives evaluated. Each of the alternatives has beenevaluated with respect to: technical advantages, disadvantages, and limi-tations; cost; environmental factors; implementability; and institutionaland regulatory considerations.

    on-site encapsulation, on-site treatment, and off-site disposal optionswere analyzed in detail. The No Action alternative was eliminated fromevaluation during the screening process. This was due to the fact thatthe existing piles were a means of temporary storage, and they do notconply with technical requirements of RCRA (i.e., no synthetic liner, noleachate collection system). This is in addition to the potentialcontamination to ground and surface waters from the stockpiles.

    The On-Site Encapsulation alternative involves the construction of a cellon-site for the permanent containment of the stockpiled soil material?

    The design of such a system would comply with the technical requiresof RCRA, which in this case would include protection from a 100-yearflood occurrance, placement of monitoring wells around the cell, and aproper liner and capping system. Several technical disadvantages ofthis alternative are:

    1. Although construction of an on-site disposal facility would be incompliance with appropriate RCRA regulations, the high ground watertable and subsurface soils are generally not suitable for constructionof a land disposal facility.

    This also is consistant with Pennsylvania regulations, which requirethat a separation of at least four feet be maintained between theseasonal high elevation of the shallow (perched) water table andthe base of the encapsulation cell.

    2. The on-site material (incinerator residue) upon which the cellwill be placed contains organic matter and is difficult to con-pact. The possibility exists for differencial settlement tooccur which may adversely affect the integrity of the cell andallow for the release of the contained material.

    3. The depth to ground water at the site has been measured to be aslittle as 2 - 5 feet below the surface. In the event of a releaseof contaminated material from the cell, migration of contaminantsto the shallow ground water table could be expected.

    AR300039

  • - 6 -

    Besides these factors, the Pennsylvania Department of Environmental Re-sources prohibits the placement of encapsulation cells within the 100-year flood plain, regardless of the flood protection provisions made.

    The other alternatives evaluated all require verification sanpling andanalysis of the stockpiled soil to determine whether or not it presentlyexceeds the key indicator parameters established for this project. Theroost recent analytical results indicate that approximately 25% of thesamples taken from the piles fail the RIA. However, the samples weredrawn from the upper layers of the piles. Degree of contamination ofthe soil at greater depths is unknown. For the purposes of developingcost estimates for the alternatives which include off-site disposal ofsoil, it was assumed that 50% of the soil in the stockpiles is currentlycontaminated (i.e., will fail the KIA test). This percentage was de-rived using the latest analytical results, and includes a 25% contin-gency due to the uncertainty associated with the degree of contaminationof the soil in the inner portions of the piles. The remaining 50% ofthe soil was assumed to be noncontaminated and suitable for use asbackfill on-site.

    The on-site treatment alternatives (Land Treatment, Composting, andSoil Aeration) are all source control measures which call for treatmentof the soil which exceeds the key indicator limits with the goal of re-ducing the degree of contamination through aeration and biodegradation.After a batch of soil receives treatment, it would be tested and, if itstill exceeds the parameters, it would be taken off-site for disposal atan approved landfill.

    In the Soil Aeration alternative, treatment of the soils would be ac-complished by using "mechanical equipment to agitate, mix, and aeratethe soils. Some technical uncertainties are associated with thisoperation since mechanical aeration of soils has not been extensivelyused in the past. The moisture content and consistency of the soilswould need to be controlled to insure that the soils can be physicallymixed and will not jam or plug the equipment. In addition, the resi-dence time and agitation required to achieve an acceptable level ofdevolatilization is not known.

    In the Cmiî ustinq alternative, biological treatanent of the soil would'be employed to achieve contamination reduction. Even though compostinghas proved successful for municipal sewage sludge, its application tocontaminated soils has not been proved. There are also technical un-certainties regarding the microorganisms and nutrient seed material tobe used, and the degree of success which can be expected from the process.

    Cie land Treatment alternative involves spreading and cultivating of thecontaminated soils. Cultivation would be performed using agriculturalequipment such as disc harrows, rakes, or plows. Contamination reductioncould be achieved by volatilization and biodegradation. Although landtreatment has been used successfully for many years in the petroleum re-fining industry, the rate or levels of treatment that can be achievedfor the waste contained in the stockpiled soil is unknown. As stated

    f l R 3 0 0 0 l i O

  • - 7 -

    earlier, the ground water level at this site has been measured to be aslittle as 2 - 5 feet below the surface. If the land treatment techniquewere implemented and reduction of the hazardous waste were not achieved ,the migration of the contaminants to the shallow ground water table couldresult.

    The Off-Site Disposal alternative would require that any soil which failedthe KIA test be taken to an approved, permitted facility for ultimate dis-posal of the contaminated soil. The soils would be excavated from thestockpiles in lots of 100 cubic yards. The sampling protocol will providefor a variable sampling frequency per soil lot to ensure a high degree ofsampling sensitivity. Any soil lots that do not exceed the key indicatorlimits will be backfilled on-site in area's having no planning futuredevelopment. The site will be covered with an impermeable clay cap toprevent potential leaching of any residual contamination into the groundwater. The material taken off -site for disposal would be manifested inaccordance with RCRA. Tfcere are no technical uncertainties associatedwith this alternative. Standard construction, excavation, and earthmoving equipment and techniques will be employed. Existing permittedhazardous waste facilities will be allowed to accept the waste from thissite. In fact, this was the alternative ijnplemented for the previouscleanup effort at this site. The environmental concerns associated withthis alternative are minimal. This alternative provides the additionalbenefit of preserving the planned use of this site for a waste treatmentfacility.

    The cost of the various alternatives range from $3.0M to $5.3M, excludingthe No Action alternative. The following is a tabulation of the costestimates for the alternatives.

    Cost Sunnary for Remedial Actions

    Estimated Capital Estimated PostAlternative Construction Cost Closure Cost*

    1. Soil Aeration $4,595,000 $ 66,0002. Land Treatment 4,238,000 66,0003. Composting 5,297,000 66,0004. Cn-Site Encapsulation 3,006,000 154,0005. No Action - 0 - 154,0006. Off-Site Disposal 4,324,000 49,000

    *Present worth computed over 30 years at a 7 3/8% discount rate,

    flR3000U

  • - 8 -

    RELATIONS

    The Draft Feasibility study vas made available for public coranent. Copiesof the document were placed in repositories in the vicinity of the site. Anotice was placed in the local newspaper regarding the availability of theFeasibility Study for public review, and to announce that a public meetingwas scheduled for February 23, 1984. The meeting was held at the City ofPhiladelphia's Southwest Water Pollution Control Plant, and was attendedby representatives of EPA, the Pennsylvania Department of EnvironmentalResources, the City of Philadelphia Water Department, and several citizen/environmental action groups.

    Basically, the comments received from the public expressed their displeasurewith the lack of detailed information in the Feasibility Study, and indicateda strong preference for implementing the alternative requiring off-site dis-posal of all soil determined to be contaminated. They were adamantly opposedto implementation of any of the alternatives calling for on-site containmentor treatment of contaminated soil. The public comment period closed threeweeks after the study was made public.

    In response to the public comments received, extensive revisions were made tothe Feasibility Study, greatly increasing the degree of detail and supportingdocumentation for the alternatives considered for cleanup.

    CONSISTENCE WITH OTHER ENVIRONMENTAL

    All of the alternatives evaluated (except No Action) were formulated to bein compliance with RCRA land treatment, storage, and disposal technical andadministrative requirements whenever possible. Included were the physicalcontrols necessary (i.e., monitoring wells, leachate collection systems,liners, etc.) to implement the on-site treatment and disposal alternatives.The cost estimates developed for the alternatives took into account theRCRA technical and administrative requirements which apply to the individualremedial actions. The recommended alternate of off site disposal providesa beneficial effect on the 100 year flood plain.

    REOCMMEMDED ALTERNATIVE

    .Section 300.68 (j) of the National Contingency Plan (NCP) [47 FR 31180,July 16, 1982] states that the appropriate extent of remedy shall bedetermined by the lead agency's selection of the remedial alternativewhich the agency determines is cost-effective (i.e., the lowest costalternative that is technologically feasible and reliable) and whicheffectively mitigates and minimizes damage to and provides adequateprotection of public health, welfare, and the environment. Based onour evaluation of the cost-effectiveness of each of the proposed alter-natives, the comments received from the public, informations from theFeasibility Study, and information from the City of Philadelphia, werecommend that the Off -Site Disposal alternative be implemented. Thisalternative includes: Resampling and analysis of the stockpiled soilsin 100-cubic-yard lots for the key indicator parameters; on-site con-tainment of soils which do not exceed established parameter limits;off-site disposal at RCRA approved facility of soils which exceedestablished parameter limits; grading, completion of clay cap and cover,and vegetating of the site.

    AR30001+2

  • - 9 -

    The recommended alternative is the least cost alternative that is tech-nically feasible and reliable, and which effectively mitigates andminimizes damage to and provides adequate protection of public health,welfare, and the environment. It also complies with RCRA by callingfor off-site disposal of contaminated soil at a RCRA approved facility,and the level of cleanup was determined in a manner consistent with theRCRA methodology. In comparison, the alternatives evaluated callingfor on-site treatment of contaminated soil by composting and aerationare more costly, and the reliability of the processes associated withtreatment of the waste present in the soil on-site is uncertain? theLand Treatment alternative, although less costly than off-site disposal,has technical uncertainties associated with it, and failure to achievethe desired contaminant reductions could result in migration of hazardoussubstances to the shallow ground water table; the On-Site Encapsulationalternative is less capital cost intense, however, it will require alonger term 0 & M period at a much higher cost than the recommendedalternative, is not as technically reliable as the Off-Site Disposalalternative, and the high ground water table and fill material at theShterprise Avenue site are generally not suitable for construction of anon-site disposal facility so long as there is another viable cost-effectivealternative for disposal. Although the on-site cell would be designed;o guard against releases, the hydrogeologic conditions at the sitei.e., high ground water table, located within the 100-year flood plain)would multiply the adverse effects of any failure of the cell which mayxrcur.

    rhe capital cost for the recommended alternative is estimated to be34,324,000. The monitoring and maintenance costs are estimated to be549,000 (present worth value) for a period of thirty years. A breakdown3f the capital costs appear in Appendix C.

    OPERATION AND MAINTENANCE (0 & M)

    Itie O & M activities associated with the recommended alternative are in-spection of the site (1 crew-day/year) and maintenance of the vegetatedrover (5 crew-days/year) at an annual cost of approximately $4,200. She:ity of Philadelphia will assume full responsibility for 0 & M since itis a city-owned property.

    PROPOSED ACTICN

    * request your approval of the removal of all soil from the EnterpriseAvenue site which fails the established Key Indicator Parameter test.It:is action will complete the cleanup of this hazardous waste disposalsite. Tte estimated total cost for this state-lead project is S4.82M,which includes the cost for construction management. We also requestan allocation of $2.41M from the Superfund to fund this cleanup at the5C% level since it is a municipally owned site.

    PPOJECT SCHEDULE

    - Approve Record of Decision May 1984- Award Cooperative Agreement for Construction May 1984- Start Construction July 1984- Complete Construction November 1984

    AR3000I43

  • i it j ̂ i

    CITY OF PHILADELPHIAENTERPRISE AVENUE SITEREMEDIAL ACTION PROGRAM

    GROUNOWATER AND SURFACE WATER MONITORINGGENERAL REPORT

    SEPTEMBER, 1981

    W.O. 1290-06-01

    TECHNICAL REPORT £

    ROY F. WESTON, INC.

    Weston WayWest Chester, PA 19380

    AR3000l*l*

  • ^,5- SELECTION OF MONITORING WELLS £

    The results of the survey of present conditions were reviewed with thePhiladelphia Water Department in May 1981. Ni'ne'moni tor ing wells wereselected as follows:

    • Four wells for shallow- zone water monitoring (PWD's #12S, 64$65S and 55S). The latter would be a new w e l l .

    • Five wells for deep zone water monitoring v.'WO's £140, 440, 64D 550r57D). Numbers 550 and 640 were new wells. The location ofthese wells is shown in Figure 1.

    All wells selected for monitoring purposes were fitted with locking capsto preserve the integrity of the monitoring program.

    The location arrangement provides three well pairs (shallow well neara deep well). Pair PWO #645 and 640 is located sou:-h of the site andpair PUD #12$ and 440 is located east of the site. These two pair providedown-gradient measurements. Pair PWO "555 and 550 ore located northwestof the site and provide up-gradient background

    Since PWD £550 and "640 w i l l also be used for water level monitoringand recording, both of these wells were constructed as to accomodatemon i tor ing equipment.

    6. WELL CONSTRUCTION '

    Wells selected for monitoring were inspected for integrity and, in thecase of pairs of wells (shallow and deep), to confirm isolation betweenwe J 1 s .

    The d r i l l i n g of the new wells, installation of casings, caps and waterlevel records was completed in July 1981.

    The 'sampl ing program was mi tiated in August/ 1981. The analyticalprogram description and i n i t i a l results are presented in TechnicalReport #4.

    • AR3000I45

  • Table 1

    Honi tor Wel 1 Survey

    Well /]'

    PWD-1S-25-35-*»S

    -55-65-75-as-9S

    -105-110-us-12S-13S-1^0-US-155-16D-16S-175-185-195-205

    -215-22S

    -235-2^5

    ""Depth"W20

    8.510

    11.5

    17.511.536.51526.5kS.S

    15152k. S1516.526.51525.520 '21.52020202036.5

    ScreenSett i ng(ft)

    X

    /

    / 78

    Not Found

    79

    ! ^1*20k2

    Not Found

    15Not Found

    23Hi

    Not FoundNot FoundDestroyed In

    212020

    Not Found

    2018

    20

    33

    Present Death(fcj

    7.610.0

    5.0

    9.3.*

    -*

    32.5-

    13.5

    23.0Id.O

    1979Slocked2018

    2018--33

    Death to Water(f t)

    3.8k.Q

    k.7

    3.̂ 2«--——3.84

    5. 00

    7.62' 2.26

    12.7213.25

    13-30 •1M--

    ' ̂ -o

    (2)

    (1) "S" denotes shallow w e l l , ":(2) Blank indicates not checked

    dee? w e l 1

    A R 3 0 0 0 U 6 °*/6ft!

  • Tabla I

    Monitor Well Survey(Cont inued)

    Vei l if Depch Setting

    PWD-25S-265-275-285-295-305-315-325-33S-34S-355-36S-375-385-400-410-420-430-440-450-465-475-485-495-550

    ^fsfrT)

    TfIT2021.6 /

    20 /20

    2020 1915-5 1521.5 / 1920 1926.5 23.525 2325 23.525 ' 24254040353532 3040

    33.59.5 9.5

    Present Ccoth Depth to Wateri ft)——Not Found »

    Not Found

    Not FoundNot FoundNot Found

    13.0 . 6.65

    9.75 3.6519- .9-2713.7 7.47

    Not Found

    Not Found20.0 12.9516.7 14.40

    Not FoundNoc FoundNot Found

    Noc Found

    Destroyed in 1979-30 9.10

    Not FoundNot Found

    Not Found

    Not Found

    Not Found

    Not Found ( R c d r i M n d )15 ^.75

    A R > 3 0 0 Q l * 7

  • Table 1

    Moni tor We Ii Survey(Continued)

    Well 9

    PWO-57D-58S-595-60S

    -61S-62S-63S-64S-640-65S-66S-67S-68S'-695-70S

    x^ TotalDepthTH750 /T9.5 ''16.5/292521 51521.5;35-011.5\\.$1516.531-528.5

    Screen-Set ting

    (ft)

    4K51613272120

    13213*9

    Present Depth(ft)

    M.516U.527212010

    213A13-8

    Not Found

    Not FoundNot Found

    Not FoundNot Found

    Depth to Water(ft)

    U.308.474.153.827-052.862.426.556.759.05

    AR30001+8 "**>

  • V. SUMMARY

    The CIty of Phifadelphla Water Department has retained WESTON for engineer!ngservices relative to a remedial action program for the Snierprisc AvenueSite. One element of the program involves a groundwator end surface wotermonitoring program. The objective of the program is r.o identify potentialmigrat ion af^any contaminants from-the site.

    The water quality monitoring program involves monthly sampling of bothgroundwater and surface water.. An expanded analyses w i l l be perfornedevery sixt.i month beginning with the first month*

    The first monthly sampling round has been performed and analysis resultsare presented,

    2. INTRODUCTION

    In March, 198! the City of Philadelphia Water Department retained'VESTONfor engineering services relative to a remedial action program for theEnterprise Avenue Site. As part of the program, a grcunrfwoter and surfacewater monitoring program is being performed to identify potential migrationof contaminants from the site. The program requires monitoring the shallowand deep water-bearing-zones as well as several surface water locations,

    3. GROUriDWATER QUALITY MONITORING

    As described above, the shallow and deep water-bearing-zones are beingmonitored utilizing groundwater wells. There are four wells (PWO £J2S,55S, 6^5 and 65S) constructed into the shallow zone "d five wells (PVO£14D,kkQ, 55D, 570, and 6̂ 0} constructed into the deep zone. The locations ofthese wells are indicated on Figure 1,

    The nine wells described arc being used to collect groundwater samplesneeded to monitor potential migration of any contaminants from the site.

    Samples are being taken from each well on a monthly bjsis. Initial sampleswere taken in August, 1981. Sampling will continue throughout the fieldwork and for twelve months subsequent to site closure. Every six months, Jfrom theTnTfTation of the sampling, an expanded set of analyses will beperformed until twelve months after site closure.

    The following monthly key Indicator analyses w i l l be performed on the watersamples:

    nH * *™

    TOC - ^ •-'">; ovocTOSSpecific Conductance

    A R 3 0 0 0 5 0

  • CITY OF PHILADELPHIAENTERPRISE AVENUE SITEREMEDIAL ACTION PROGRAM

    Groundwaier and Surface Water Monitoring Program:Monthly Analysis Results Report

    September, 738J. W,0, 1230-06-07

    TECHNICAL REPORT

    /I

    ROY F, WESTON, INC,.We ston Way

    Vest Chester, PA

    AR30005

  • Twice per year, from initiation-of sampling, an expanded sec of analyseswil l be performed. The expanded analyses includes:

    Priority pollutant analysisFluorideAmmonla-Mi trogenNi trat^-Ni trogenpK-TOSSpec ific ConductanceTOCVOCCyanide 'Silver /Zinc /

    ArsenicBar turn .

    Chroni*urnHex. ChromiumCopperI ronLeadMccury5el on iumTi ten i urn

    A WESTON/City Water Department team will collect the. sa.r.ples and theanalyses wilT be performed in WESTON*s laboratory. The results are tobe reported to the City with appropriate Tnterprctation as applicable.

    k. SURFACE WATER MONITORING . '

    Surface water samples are being collected on a monthly and biannual frequencyconcurrently with the groundwater samples. Five surface water samplingstations as indicated on Figure 1, are included as follows:

    Stat ion

    S-4

    S-8

    S-10

    S-11

    S-12

    locat ion

    Background on Eagle Creek.

    Background south of the la n d f i l l at FortMifflin,

    Eagle Creek adjacent to the landfill.

    Background on tributary to Eagle Creek.•

    Eagle Creek downstream from landfill.

    Samples are being collected at these stations and analyzed for the saneparameters as the groundwater samples. The need to collect and analyzesurface water samples during actual storm runoff conditions is being assessedand the surface water sample collection schedule may be altered accordingly.

    »

    5- ANALYSIS RESULTS.* t

    Presently, the first monthly sampling round has been performed- Table 1presents the results for August, 1981,

    Due to the time of year, and the minimal rainfall some wells were dry.these instances, the expanded set of analyses were postponed until thesecond month.

    '

  • A R 3 0 D - 0 5 3fS-

  • V ~. o 3jj^ • " o » o » ». » v .^ » o

    r *•* ci " S I 2 " " " 0 0 * " "

    Oo

    515

    a — »• mMo 8 *-» » a * * *

    O .•• —— V*. **«...8 *"

    "t? g Z? 1? — o ff •"* _ ! . _ - - - . •

    5 15 t1 -J io Z C

    f t flR30005.»>. l